Case 2:15-cv-01768-DJH Document 1 Filed 09/03/15 Page 3 of 19
subject to threats and extortion. The defendants are the website operators and Internet
Service Providers who are hosting the stolen data to facilitate public searches, often for a
fee. Through this action, Plaintiffs allege civil receipt of stolen property under California
law, violation of California’s Unfair Competition Law, intentional and negligent infliction
of emotional distress, and violation of the Computer Fraud and Abuse Act, 18 U.S.C. §
1030 on behalf of Plaintiffs John Doe 1 through 3 and against GoDaddy.com, LLC
(“GoDaddy”), Amazon Web Services, Inc. (“Amazon”), and Roes 1 through 20
(collectively, the “Roe Defendants”).
JURISDICTION AND VENUE
This Court has subject matter jurisdiction over Plaintiffs’ federal Computer
Fraud and Abuse Act, 18 U.S.C. § 1030.
This Court has supplemental jurisdiction of Plaintiffs’ state law claims
pursuant to 28 U.S.C. § 1367(a) in that these state law claims are so related to the
Computer Fraud and Abuse Act claim raised in this Complaint that they form part of the
same case or controversy under Article III of the United States Constitution.
Alternatively, this Court has subject matter jurisdiction under 28 U.S.C. §
1332 because the matter in controversy exceeds the sum or value of $75,000, exclusive of
interest and costs, and the action is between citizens of different states. To wit, Plaintiffs
are citizens of and domiciled in California, New Jersey, and Maryland, while Defendants
are citizens of and domiciled in Delaware and Arizona.
Venue is proper under 28 U.S.C. § 1391 because many of the incidents,
events, or omissions complained of and giving rise to the instant claims and controversy
occurred within the State of Arizona and this District.
This Court has personal jurisdiction over Defendants because Defendants,
and each of them, do substantial business in Arizona and purposefully direct substantial
activities as the residents of Arizona by means of the Internet services and websites
described herein. Defendants, and each of them, have done substantial and continuous
business with Arizona residents and have purposefully directed substantial and pervasive